The Ultimate Guide to Data Protection Impact Assessments

In today’s data-driven world, organizations collect and process vast amounts of personal data, making data protection a critical concern.

Lucky for us, the General Data Protection Regulation (GDPR) has introduced the concept of Data Protection Impact Assessment (DPIA) as a tool to help organizations assess and manage privacy risks associated with their data processing activities.

DPIAs are like armor for organizations, protecting them from the risks of noncompliance with data protection regulations and safeguarding the rights and freedoms of individuals. In this ultimate guide, we’ll give you the lowdown on DPIAs, including what they are, when you need them, and how to conduct them like a pro.

Whether you are a data protection professional or an organization looking to protect personal data, we’ve got everything you need to know about DPIAs right here. Get ready to level up your data protection game!

What is a DPIA?

A DPIA, or Data Protection Impact Assessment, is a process that helps organizations identify and mitigate risks to the privacy rights and freedoms of individuals when processing their personal data.

What is the purpose of a DPIA?

The purpose of a DPIA is to assess the potential impact of a proposed or existing data processing activity on individuals’ privacy rights and freedoms, and to identify any measures that can be taken to reduce or eliminate these risks.

By conducting a DPIA, organizations can identify and mitigate risks before processing activities are implemented, which can help avoid potential data breaches and reputational harm.

What are specific requirements for conducting a DPIA?

The GDPR sets out specific requirements for conducting a DPIA, including the following:

Overall, DPIAs are an important tool for organizations to ensure that they are complying with data protection regulations and protecting individuals’ privacy rights and freedoms.

When is a DPIA required under GDPR?

Under the GDPR, DPIAs are required when processing activities are likely to result in a high risk to the rights and freedoms of individuals.

The GDPR sets out the following circumstances in which a DPIA is required:

1. Processing of sensitive personal data

A DPIA is required when processing sensitive personal data, such as health data, genetic data, biometric data, or data relating to criminal convictions and offenses.

2. Large scale processing

A DPIA is required when processing personal data on a large scale. This could include processing activities that involve a large number of individuals’ personal data, or processing activities that cover a large geographical area.

3. Systematic monitoring

A DPIA is required when processing personal data through systematic monitoring of a publicly accessible area on a large scale, such as through the use of CCTV (closed-circuit television) or other surveillance systems.

4. Profiling

A DPIA is required when processing personal data through profiling, which involves the automated processing of personal data to evaluate certain personal aspects of an individual, such as their performance at work, their economic situation, their health, or their personal preferences.

5. Processing that poses a high risk to individuals' rights and freedoms

A DPIA is required when processing personal data is likely to result in a high risk to the rights and freedoms of individuals, such as where the processing involves automated decision-making with legal or similarly significant effects, or where it involves the processing of personal data on a large scale, including data concerning vulnerable individuals, children or other sensitive data.

Overall, the circumstances in which a DPIA is required will depend on the specific data protection legislation in question and the nature of the processing activities involved.

Organizations should carefully assess their processing activities to determine whether a DPIA is required, and seek advice from their DPO (data protection officer) or other experts if they are uncertain.

Who should conduct a DPIA?

According to the GDPR, a DPIA must be carried out by the controller of the personal data.

The data controller is the natural or legal person, public authority, agency, or other body that determines the purposes and means of the processing of personal data.

Therefore, it is the organization or entity that collects and processes the personal data that is responsible for conducting a DPIA.

In some cases, the controller may delegate the responsibility of conducting a DPIA to a processor or a third-party consultant. However, it’s important to note that the controller remains ultimately responsible for ensuring that a DPIA is conducted when required and that the assessment is carried out effectively.

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What is the DPO's role in conducting a DPIA?

While the DPO is not necessarily the person who conducts the DPIA, they are ultimately responsible for ensuring that the DPIA is conducted correctly and in accordance with the requirements of the GDPR.

As a result, they are well-placed to perform the Pre-DPIA, as they have a good understanding of the processing activities and the potential privacy risks and impacts. However, it is important to note that the Pre-DPIA process is not mandatory under the GDPR. Instead, it is a good practice that can help organizations to assess whether a full DPIA is necessary, and to identify and address potential privacy risks and impacts at an early stage.

The DPO’s role in the DPIA process may include the following:

1. Advising on the need for a DPIA

The DPO can help the data controller determine whether a DPIA is required for a particular processing activity, based on an assessment of the risks to individuals’ rights and freedoms. To determine whether a full DPIA is necessary, the DPO may conduct a Pre-DPIA

What is a Pre-DPIA?

A Pre-DPIA (aka preliminary screening) is a process that may come before a full DPIA. The purpose of a Pre-DPIA is to assess whether a full DPIA is necessary for a particular processing activity, based on an initial analysis of the potential privacy risks and impacts.

A Pre-DPIA may be conducted when:

The Pre-DPIA process typically involves a preliminary analysis of the processing activity, including an assessment of the data protection risks and impacts, and an evaluation of whether a full DPIA is required.

If it is determined that a full DPIA is required, the Pre-DPIA report can be used as a starting point for the full DPIA process.

2. Providing guidance on conducting a DPIA

The DPO can provide guidance on the methodology and approach for conducting a DPIA, including the assessment criteria, the risk assessment process, and the documentation requirements.

3. Ensuring the DPIA is completed

The DPO should ensure that the DPIA is completed in a timely and effective manner, and that all relevant stakeholders are involved in the process.

4. Reviewing and approving the DPIA

The DPO should review and approve the DPIA report before it is submitted to the relevant supervisory authority, to ensure that it is accurate, complete, and compliant with GDPR requirements.

5. Monitoring the implementation of the DPIA

The DPO should monitor the implementation of the DPIA’s recommendations and ensure that the privacy risks identified are adequately addressed.

What are the steps involved in conducting a DPIA?

The process of conducting a DPIA typically involves several key steps, including scoping, data mapping, risk assessment, and risk management. Here is an overview of each step:

1. Scoping

The first step in conducting a DPIA is to define the scope of the assessment. This involves identifying the processing activities to be assessed, the data flows involved, and the potential risks to individuals’ privacy rights and freedoms. It’s important to involve key stakeholders in this process, including data controllers, processors, and data protection officers (if applicable).

2. Data mapping

The next step is to map out the personal data being processed, including the categories of data, the purposes of processing, and the data recipients. This can be done using data flow diagrams or similar tools to provide a visual representation of the data flows.

3. Risk assessment

The next step is to assess the potential risks to individuals’ privacy rights and freedoms arising from the processing activities. This involves identifying the potential impact on individuals, such as loss of control over personal data, discrimination, reputational harm, or financial loss. The likelihood of these risks occurring should also be assessed.

4. Risk management

Once the risks have been identified, the next step is to develop risk management strategies to address them. This may involve implementing technical or organizational measures to reduce the risks, or modifying the processing activities to minimize the impact on individuals. Risk management strategies should be proportionate to the risks identified and should take into account the rights and freedoms of individuals.

5. Review and update

Finally, it’s important to review and update the DPIA on a regular basis to ensure that it remains relevant and effective. This may involve revisiting the risk assessment and management strategies in light of new developments or changes to the processing activities.

Overall, conducting a DPIA requires a systematic and thorough approach, involving a range of stakeholders and a comprehensive assessment of the potential risks to individuals’ privacy rights and freedoms.

By following these steps, organizations can ensure that they comply with data protection regulations and protect the privacy of the individuals whose personal data they process.

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What are some key considerations to keep in mind when conducting a DPIA?

When conducting a DPIA, there are several key considerations that organizations should keep in mind to ensure that the assessment is effective and meets the requirements of data protection regulations. Here are some important considerations:

1. Involving data subjects

It’s important to involve data subjects in the DPIA process to ensure that their rights and interests are taken into account. This may involve consulting with data subjects or their representatives, such as through focus groups, surveys, or other means. By involving data subjects in the DPIA process, organizations can gain a better understanding of the potential impact of the processing activities on individuals and tailor risk management strategies accordingly.

2. Documenting the DPIA process

It’s important to document the DPIA process in detail, including the scope of the assessment, the data mapping exercise, the risk assessment and management strategies, and any other relevant information. This documentation should be kept up to date and made available to relevant stakeholders, such as data protection authorities, if requested.

3. Consulting with data protection authorities

Depending on the nature of the processing activities, it may be necessary to consult with data protection authorities during the DPIA process. This may involve seeking guidance on specific aspects of the assessment or obtaining approval for the processing activities. Organizations should familiarize themselves with the relevant data protection regulations to determine when consultation with data protection authorities is required.

Which are relevant data protection authorities?

When it comes to DPIAs, the relevant data protection authorities are both the national Data Protection Authorities (DPAs) in each EU member state and the European Data Protection Board (EDPB). These entities are responsible for enforcing data protection regulations and ensuring that organizations comply with the GDPR and other applicable data protection laws within their jurisdictions.

Each member state has its DPA, which is accountable for supervising the processing of personal data within its jurisdiction. DPAs have broad authority, including the ability to conduct inspections and investigations, issue fines, and require organizations to take corrective action if they are found to be in violation of data protection regulations.

The EDPB, on the other hand, is an independent European body that works to ensure the uniform application of data protection rules across the EU. It provides guidance on conducting DPIAs and enforcing data protection regulations, and it has the power to make binding decisions in certain cases and coordinate the activities of national DPAs.

4. Integrating DPIA into organizational processes

Conducting a DPIA should not be a one-off exercise, but rather an ongoing process that is integrated into organizational processes. This may involve incorporating DPIA into project management processes or risk management frameworks to ensure that privacy considerations are taken into account throughout the lifecycle of processing activities.

5. Ensuring transparency

Finally, it’s important to ensure transparency throughout the DPIA process, both with respect to data subjects and other relevant stakeholders. This may involve providing clear and concise information about the processing activities and their potential impact on individuals, as well as making the DPIA documentation available to relevant stakeholders upon request.

Overall, conducting a DPIA requires a careful and systematic approach that takes into account the interests and rights of data subjects, involves consultation with relevant stakeholders, and is documented and integrated into organizational processes. By following these considerations, organizations can ensure that they comply with data protection regulations and effectively manage the risks associated with processing personal data.

DPIA tools and resources

There are several great tools and resources available to organizations that are looking to conduct a DPIA. By leveraging these resources, organizations can ensure that their DPIA process is thorough, effective, and compliant with data protection regulations. Here are some examples:

DPIA templates

Many data protection authorities, such as the ICO in the UK and the CNIL in France, provide DPIA templates that can help organizations structure and document their DPIA process.

Guidelines and checklists

Several organizations, such as the International Association of Privacy Professionals (IAPP), provide guidelines and checklists that can help organizations conduct a DPIA. These resources often include step-by-step instructions, best practices, and risk assessment frameworks.

DPIA software

There are several DPIA software tools available that can help automate the DPIA process, including data mapping, risk assessment, and documentation. These tools often include pre-built templates, workflows, and reporting features.

Industry-specific guidance

Some industries, such as healthcare and finance, have specific regulations and guidelines that require organizations to conduct DPIAs. There are several industry-specific resources available that provide guidance on conducting DPIAs in these contexts.

Expert consultants

Finally, organizations can engage expert consultants who specialize in data protection and privacy to assist with conducting a DPIA. These consultants can provide valuable guidance on best practices, regulatory requirements, and risk management strategies.

Check out our blog

4 steps to execute flawless DPIAs

What are the best practices for conducting a DPIA?

Here are some DPIA best practices to consider when conducting a Data Protection Impact Assessment:

1. Maintain transparency

It’s important to be transparent with data subjects about the processing activities being conducted and how their personal data is being used. This can help build trust and ensure that data subjects are fully informed about their rights and how to exercise them.

2. Involve key stakeholders

DPIAs should involve all relevant stakeholders, including IT, legal, compliance, and security teams. This ensures that all risks and issues are identified and addressed, and that the DPIA is comprehensive and effective.

Don’t forget to involve data subjects wherever possible, particularly if the processing activities are likely to have a significant impact on their privacy rights. This includes providing information about the DPIA process and seeking input on the processing activities and any concerns they may have.

3. Consider the full data lifecycle

DPIAs should consider the entire data lifecycle, from collection to deletion, and identify potential risks and issues at each stage. This includes understanding the purposes for which data is collected, how it is processed, who has access to it, and how it is stored and protected.

4. Adopt a risk-based approach

DPIAs should adopt a risk-based approach, assessing the potential impact of data processing activities on data subjects and identifying and mitigating risks. This includes assessing the likelihood and severity of harm, and considering the effectiveness of controls and safeguards.

5. Document the DPIA process

It’s important to document the DPIA process, including the methodology used, the risks and issues identified, and the actions taken to mitigate those risks. This documentation can be used to demonstrate compliance with data protection regulations and to identify areas for improvement.

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Written by

Yannick Vranckx

Marketing Specialist @ RESPONSUM

DPIA – Data Protection Impact Assessment

Data Protection Impact Assessment

Effortlessly manage risks in planned and ongoing activities, safeguard your business from legal and reputational risks, and ensure compliance with data protection regulations. Simplify and streamline your organization’s Data Protection Impact Assessments (DPIAs) with the help of RESPONSUM.


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What is a DPIA?

The DPIA is a crucial part of the Data Protection by Design principle, covered by Article 35 of the GDPR. Its main goal is to help organizations assess and control privacy risks linked to their data processing activities, ensuring they follow regulations and protect people’s privacy. To achieve this, organizations map out their processing procedures, evaluate potential risks, and put measures in place to reduce those risks.

DPIAs become necessary whenever processing activities are likely to pose a notable risk to individuals’ rights and freedoms. As a standard practice, they typically involve the following steps:

Challenges of a DPIA

The GDPR does not go into specifics on how to execute a DPIA, yet certain Supervisory Authorities, like the French CNIL (Commission Nationale de l’Informatique et des Libertés) have already published guidelines on the topic. However, experience shows that the biggest challenges of performing a DPIA are more practical:

Getting accurate information

When the privacy team is not immediately involved in every project, you’re often unsure whether you have the latest or even complete information.​

Past actions documentation

In order to be compliant and meet the accountability requirement in GDPR, organizations are required to document their past assessments and actions  – not an easy feat in a spreadsheet.

Receiving information in time

Often, the biggest time-consumer is receiving information from colleagues. Everyone is busy, and it’s up to the privacy team to properly follow up on their requests.​

Continuous reevaluation

As organizations and processes change, DPIAs should be continuously reviewed and reassessed. Keeping track of those review schedules and consequential actions is no easy task.


Guided DPIA process

Experience effortless navigation with RESPONSUM! Our user-friendly interface guides you seamlessly from scoping to the final review, ensuring all crucial information is included. Save time with instant access to data through the integrated Records of Processing Activities in our DPIA module. Need extra insights or feedback? RESPONSUM is your go-to solution. Our communication and task delegation features make reaching out to colleagues a breeze. Stay in control and up-to-date by setting up review cycles effortlessly.


Execute a quick pre-DPIA to see if a full DPIA is necessary

Identify & assess

Identify and assess the risks for the data subjects’ rights

Action plan

Decide on your action plan to mitigate the risks


Monitor and review your DPIA regularly


4 steps to executing flawless DPIAs

Dive into our blog to grasp the essence of DPIAs, understand their importance, and follow a concise guide for effective implementation. Enhance your data protection and ensure GDPR compliance.

Simplify DPIAs through software

Lynn Vleugels - Data Protection Officer

Lynn Vleugels - Data Protection Officer

“We were already keeping a good RoPA, but when we uploaded it into RESPONSUM, it was such a relief to see our data instantly available for all the other modules. It just made things so much smoother!”

Link the DPIA

Link the DPIA with other RESPONSUM solutions, such as the record of processing activities (RoPA), and have the data you need immediately available.

Clear overview

Have a clear overview of all the DPIAs in your organization and set up review cycles to ensure you are always up-to-date.

Boost communication

Enhance communication with other departments by immediately reaching out to colleagues through our built-in communication / task delegation features.

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RESPONSUM is available in 9 languages: English, French, Spanish, Dutch, Italian, Portuguese, Thai & Finnish. Require another language? Let us know!

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